If you need to write 46 pages to defend something you’ve lost the argument.
You can bet the farm he didnt write any of this.
here’s an analysis https://theconservativetreehouse.com/2020/06/01/flynn-judges-lawyer-files-response-to-district-court-says-flynn-can-defend-himself-against-independent-accusations-by-court/#more-193269
Likely 46 pages of dissembling and obfuscation.